http://www.thelog.com/local/coast-guard-continues-to-take-aim-at-illegal-charters/
You gotta love the (at best) 100 ton master giving legal advice on an extremely complicated topic.
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These charters are going on in NY and NJ. I have complained to the USCG but they continue to flourish. I keep hearing excuses like, they are non profit, they only operate in brackish waters.